Transfer pricing: CBC notification format published

In 2016, Belgium introduced additional transfer pricing documentation obligations: the CBC notification, the Local File and the Master File. These documents must be filed if certain thresholds are met.

The local file has to be introduced together with the tax return. The CBC notification and the Master File must be filed within 12 months after the last day of the reporting period of the group. For companies with a group reporting period ending on 31 December 2017, these documents must be filed on 31 December 2018 at the latest.

The formats of the reports to be used were published in the State Gazette of 2 December 2016 (form 275 CBC, the country-by-country report, form 275 MF, the master file, and form 275 LF, the local file). The explanatory note also contained a “form 275 CBC NOT” which can be used to meet the “notification” requirements for filing the country-by-country report.

A royal decree of 15 October 2018, published in the Belgian state Gazette of 24 October 2018, has converted the form into apparently an obligatory format.

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